On 25 April 2026, Decree n° 2026-310 of 24 April 2026 relating to access to the beneficial ownership register and the training obligation applicable to professionals subject to anti-money laundering and counter-terrorist financing requirements was published in the Official Journal.

The Decree introduces Article D. 561-38-1 into the French Monetary and Financial Code, supplementing Articles L. 561-34 and R. 561-38-1 thereof. It provides that training delivered to individuals involved in the implementation of anti-money laundering obligations must be more strictly regulated, including training upon recruitment and on a regular basis thereafter. Such training must enable staff to identify transactions that may be linked to money laundering or terrorist financing. It must cover the obligations set out in Chapters I and II of Title VI of Book V of the French Monetary and Financial Code (i.e., anti-money laundering obligations), as well as the sanctions applicable in the event of non-compliance with those obligations.

The new provision also requires obliged entities to maintain up-to-date records of the training completed by their staff throughout their period of employment and for five years following the end of their duties.

Lastly, this Decree notably amends Section 9 of Chapter I of Title VI of Book V of the French Monetary and Financial Code, relating to the filing of information concerning beneficial owners.

This Decree entered into force on 26 April 2026.

Source: Publication of Decree n° 2026-310 on access to the beneficial ownership register and the training obligation for professionals subject to AML/CFT

On 7 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a document setting out the technical specifications applicable to Small and Non-Complex Undertakings and Small and Non-Complex Groups, following the adoption of Directive 2025/2 of 27 November 2024 amending Directive 2009/138 of 25 November 2009 (“Revised Solvency II”).

Revised Solvency II strengthened the framework for implementing the principle of proportionality, in order to ensure that regulatory requirements are applied in a manner proportionate to the nature, size and complexity of the undertakings and groups concerned. These changes include the creation of a new category of undertakings and groups referred to as small and non-complex.

EIOPA recalls that these entities are identified on the basis of quantitative and qualitative criteria, in accordance with Articles 29a and 213a of Revised Solvency II, which must be met on an ongoing basis over two consecutive financial years.

The purpose of this technical document is to provide operational guidance to undertakings and supervisory authorities in order to facilitate the proper identification of eligible undertakings and groups and the consistent calculation of the applicable risk indicators.

The overall objective is to ensure a harmonised implementation of the new framework across all Member States as from the date of application of Revised Solvency II.

Source: EIOPA published technical specifications applicable to undertakings classified as small and non-complex undertakings and to groups classified as small and non-complex groups

European Union – EIOPA – Public consultation on the treatment of proportional reinsurance treaties containing features that may jeopardise the commensurateness between SCR relief and effective risk transfer

On 15 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) launched a public consultation on the treatment of proportional reinsurance treaties containing features that may jeopardise the commensurateness between the reduction in the Solvency Capital Requirement (“SCR”) generated by the treaty and the effective transfer of risk it provides.

Previously, in July 2021, EIOPA published an Opinion on the use of risk mitigation techniques by insurance undertakings pursuant to Article 29(2) of Regulation n° 1094/2010, providing guidance on the assessment of such techniques, including the consistency between SCR relief and effective risk transfer.

EIOPA is proposing to publish an annex to this Opinion, based on Directive 2009/138 as amended by Directive 2025/2 of 27 November 2024 (“Revised Solvency II”), in particular Articles 134(1), 172(3) and 173 thereof, as well as Commission Delegated Regulation 2015/35, notably Articles 211(2)(b) and (c), 213 and 214.

The purpose of this annex is to provide further clarification regarding the specific case of proportional reinsurance treaties containing mechanisms that may reduce such commensurateness, including sliding-scale commissions, loss corridors and loss limits. EIOPA also reiterates that insurance and reinsurance undertakings remain free to incorporate such mechanisms into their reinsurance arrangements where they are consistent with their risk management policies.

EIOPA further explains that the annex reinforces the interpretation set out in Q&A 1898, submitted to EIOPA on 1 April 2019, according to which any reinsurance commission that constitutes a measure of the cedant’s risk exposure volume is equivalent to premiums and should therefore increase the premium risk calculated under the standard formula. The annex also supplements this Q&A by providing further clarification on the treatment of fixed and variable reinsurance commissions.

Stakeholders may submit their comments until 17 July 2026.

Source: EIOPA launched a public consultation on the treatment of proportional reinsurance treaties containing features that may jeopardise the commensurateness between SCR relief and effective risk transfer

On 15 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) launched a public consultation aimed at contributing to the objective of regulatory simplification by reducing several guidelines, following the adoption of Directive 2025/2 of 27 November 2024 amending Directive 2009/138 of 25 November 2009 (“Revised Solvency II”).

This public consultation proposes shortening 13 guidelines, notably in relation to Pillars 1 and 2, through both “Type 1” deletions, covering guidelines that are redundant because they merely repeat Level 1 or Level 2 provisions, and “Type 2” deletions, covering guidelines considered to provide limited added value. Following this simplification exercise, national competent authorities will be required to review and update their national frameworks in order to remove the repealed guidelines, while continuing to ensure a level playing field and the application of a single rulebook.

EIOPA emphasises that these amendments are intended solely to clarify and simplify the existing framework and do not reduce supervisory expectations. They do not introduce any new interpretation or application of the existing legal framework.

Stakeholders may submit their comments until 8 July 2026. The revised guidelines will apply from 30 January 2027.

Source: EIOPA launched a public consultation on its proposal to shorten 13 Solvency II guidelines

On 24 April 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) submitted to the European Commission two draft technical standards intended to support the implementation of Directive 2025/1 establishing a framework for the recovery and resolution of insurance and reinsurance undertakings (the “IRRD”):

• A draft Regulatory Technical Standard (“RTS”) on the functioning of resolution colleges (EIOPA-BoS-26/129), pursuant to Article 70(7) of the IRRD. The purpose of this draft RTS is to further specify the criteria for the establishment and the practical functioning of resolution colleges, in particular: (i) the operational organisation of resolution colleges; (ii) the arrangements governing joint decisions relating to the development of group resolution plans, resolvability assessments and measures to address impediments to resolvability; and (iii) the governance of cross-border groups resolution.
• A draft Implementing Technical Standard (“ITS”) on procedures and a minimum set of standard forms and templates for the provision of information referred to in Article 12(1) of the IRRD (EIOPA-BoS-26/040). This draft ITS sets out the procedures, forms and standardised templates that insurance undertakings will be required to use when providing resolution authorities with the information necessary for the preparation of resolution plans. Its objective is to strike a balance between the information needs of resolution authorities and the reporting burden placed on insurance undertakings by requiring only information that is strictly necessary.

EIOPA is required to submit these draft technical standards to the European Commission by 29 July 2026 at the latest.

Source: EIOPA submitted to the European Commission two draft technical standards supporting the implementation of the IRRD

On 5 May 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) launched a public consultation on its draft technical advice concerning minimum common standards for insurance guarantee schemes (“IGS”) in the European Union, following the request for advice submitted by the European Commission in August 2025 and pursuant to Article 98 of Directive 2025/1 (the “IRRD”).

EIOPA aims to reduce divergences between national regimes in the event of an insurer's failure, enhance policyholder protection and ensure greater consistency between insurance guarantee schemes and the European insurance recovery and resolution framework established under the IRRD.

More specifically, EIOPA intends to examine four key areas: (i) general issues about the impact of insurance guarantee schemes harmonised on a minimum basis, (ii) the operational functioning of IGS, (iii) the conditions required for their effective funding, and (iv) the interaction between the IRRD and harmonised IGS.

EIOPA considers that targeted harmonisation, consistent with the principle of minimum harmonisation, would make it possible to address the most essential aspects of insurance guarantee schemes (scope of coverage, triggering events, funding and coordination) while preserving national flexibility where justified, particularly with regard to institutional structures.

Stakeholders may submit their comments until 26 June 2026.

Source: EIOPA launched a public consultation on its draft technical advice on minimum harmonised insurance guarantee scheme standards in the EU

The Authority for Anti-Money Laundering and Countering the Financing of Terrorism (“AMLA”) has published several documents relating to anti-money laundering and counter-terrorist financing (“AML/CFT”):

• Two public consultations were launched on 16 April 2026. They concern: (i) draft guidelines under Article 10(4) of Regulation 2024/1624 (the “AMLR”) on business-wide risk assessments, aimed at determining an entity’s risk exposure and ensuring that it has adequate AML/CFT controls in place; and (ii) a draft Regulatory Technical Standard (“RTS”) under Articles 16(4) and 17(3) of the AMLR on group-wide requirements, setting out minimum standards for AML/CFT arrangements at group level, including in cross-border situations and where obliged entities operate in third countries.

  Stakeholders may submit comments until 15 June 2026 for the draft RTS and until 15 July 2026 for the draft guidelines.

• A consultation paper published on 11 May 2026 on a draft Regulatory Technical Standardconcerning cooperation between home and host supervisors and the practical arrangements governing such cooperation, pursuant to Article 46(4) of Directive 2024/1640 (the “AMLD”). The draft RTS notably clarifies the respective responsibilities of home and host supervisors and sets out practical arrangements enabling them to cooperate to the greatest extent possible.
• A publication dated 12 May 2026 concerning reporting requirements intended to provisionally identify entities that may fall under AMLA’s direct supervision, pursuant to the Implementing Technical Standards provided for in Article 15(3) of Regulation 2024/1620 (the “AMLAR”). The publication includes: (i) an interpretative note; and (ii) a template, in tabular format, for identifying eligible entities. Its purpose is to provide reporting instructions for national competent authorities to identify entities meeting the criteria for inclusion in the 2027 selection process for direct supervision.

  Stakeholders may submit comments until 15 August 2026.

• publication dated 13 May 2026 concerning three draft Implementing Technical Standards (“ITS”) aimed at establishing harmonised formats for cooperation between Financial Intelligence Units (“FIU”), AMLA and the European Public Prosecutor’s Office (“EPPO”). AMLA also held a public hearing on these draft standards.

• Draft ITS specifying: (i) the format to be used by FIUs for reporting to the EPPO, pursuant to Article 81(1) of the AMLR; and (ii) the format to be used by AMLA for reporting to the EPPO, pursuant to Article 41(2) of the AMLAR.
• Draft ITS specifying theformat to be used for the exchange of information between FIUs, pursuant to Article 31(2) of the AMLD.

Source: AMLA publications, including two public consultations published on 16 April 2026, a public hearing held on 11 May 2026, publication issued on 12 and another publication on 13 May 2026

Authored by Ghina Farah and Maxime Kaya.